ON CORRUPTIONFighting corruption in the Philippines is like trying to kill an elephant with a flyswatter.Atty. Simeon V. Marcelo, former Ombudsman of the PhilippinesBASIS FOR COMPARISONIndonesia and the Philippines share a number of other important characteristics.

Politically, both countries experienced long periods of authoritarian rule that were characterized and sustained by rent-seeking and systemic corruption. The Marcos dictatorship in the Philippines lasted 14 years, from 1972 to 1986, while Soehartos authoritarianism endured for 31 years, from 1967 to 1998. Similarly, both authoritarian governments collapsed following popular protest movements fuelled by widespread anger against massive corruption and its precipitating role in economic crises. Moreover, both countries equally saw a burst of pluralism during their respective transitions from authoritarian rule. Numerous political parties formed, civil society organisations mushroomed, and media channels multiplied. Today, both countries are characterised by strong chief executives, with relatively weak bicameral legislatures, and a robustly decentralised local government sector.

Economically, both Indonesia and the Philippines are lower middle income countries. Indonesias Gross National Income per capita in 2008 was US$1,880 while the Philippines was US$1,890 (World Bank 2009). Their political economies are likewise similar in terms of the persistence of neo-patrimonial practices, where the structures and systems of modern government mask the practices and patterns of patronage and corruption. The respective transitions to democracy of both countries failed to dismantle the family-focused, clan-oriented, and region-sensitive ways that dominate politics and economics in interlocking ways.

In terms of corruption, both Indonesia and the Philippines are considered among the more corrupt in Asia. Both score very low in various indices such as Transparency Internationals Corruption Perceptions Index and the Word Banks Control of Corruption indicator. (Indonesias ranking, however, has improved in recent years compared to the Philippines, in part because of the work of the KPK.) When the KPK and the Ombudsman were established (in 2003 and 1988 respectively), both faced similarly high levels of state capture as well as grand and petty corruption.Bolongita, Emil P. An Exception To The Rule?. U4 Anti-corruption Resource Center Issue. August 2010: p. 7SUCCESS OF KPKIn just five years, the KPK has successfully prosecuted over one hundred senior officials that before would have been considered as untouchable by their positions and prominence. To date, the KPK has yet to lose a single case, either at the anti-corruption court or at the Supreme Court where the guilty verdicts of the TIPIKOR are appealed.Bolongita, Emil P. An Exception To The Rule?. U4 Anti-corruption Resource Center Issue. August 2010: p. 10FAILURE OF OMBUDSMANWith the notable exception of former President Joseph Estrada who was convicted of corruption in extraordinary circumstances (after he was already ousted from office), the Ombudsman cannot point to any high-ranking official that it has convicted and imprisoned for corruption.

While an exception, the conviction by the Sandiganbayan of former President Estrada for corruption in September 2007 was a major achievement of the Ombudsman during the tenure of Simeon Marcelo and Special Prosecutor Dennis Villa-Ignacio. Estrada was found guilty of plunder and sentenced to life imprisonment. The conviction was made possible in great part by the fact that Ombudsman Marcelo and Prosecutor Villa-Ignacio worked closely to marshal the strong evidence presented during Estradas impeachment trial and make a compelling case at the Sandiganbayan. This evidence, it should be noted, was unearthed not by OmbudsmanBolongita, Emil P. An Exception To The Rule?. U4 Anti-corruption Resource Center Issue. August 2010: p. 10WHAT OMBUDSMAN CAN PROSECUTEThe Ombudsman can prosecute most public officials, including the military, except for those officials that are removable only by impeachment, as well as members of Congress and members of the Judiciary. This means that officials of two of three main branches of government the legislature and the judiciary are out of the reach of this agency.Bolongita, Emil P. An Exception To The Rule?. U4 Anti-corruption Resource Center Issue. August 2010: p. 13INVESTIVATIVE POWERS: OMBUDSMAN v KPKThe KPK essentially has all the investigative powers of a law enforcement agency, while the Ombudsman does not. The KPK can, on its own accord, conduct wiretaps on suspects, examine their bank accounts and tax records, freeze suspects assets, issue hold orders and make arrests. The Ombudsman cannot wiretap, it cannot examine bank accounts or freeze assets, and it cannot make arrests.

At best, the Ombudsman can conduct surveillance but it can only use still cameras, not video recording equipment. Video recording evidence, in so far as it has audio characteristics, is proscribed under the Philippines anti-wiretapping law and thus inadmissible in court.Bolongita, Emil P. An Exception To The Rule?. U4 Anti-corruption Resource Center Issue. August 2010: p. 14PROSECUTION: OMBUDSMAN v KPKWhen KPK investigators and prosecutors agree that they have a strong case to prosecute before the TIPIKOR, their case undergoes a three-stage panel review conducted by the KPK commissioners. The commissioners role is to challenge the proposed case strategies in order to ensure that each case filed is winnable. Only when a case has successfully gone through these panel reviews will it be approved by the Commission for prosecution at the TIPIKOR. This level of preparation of the KPK contributes to the efficiency of the court as the prosecution is able to proceed methodically without seeking postponements in the trials.Bolongita, Emil P. An Exception To The Rule?. U4 Anti-corruption Resource Center Issue. August 2010: p. 14OPERATIONAL COMMUNICATION: OMBUDSMAN v KPKAt the Office of the Ombudsman, investigators and the prosecutors do not even coordinate with each other prior to the decision to prosecute or not. Unlike the KPK, Ombudsman investigators and the prosecutors are located in different buildings in different parts of Quezon City. But this physical distance is only part of the Ombudsmans incongruous arrangements in its investigative and prosecutorial functions. Unlike in the KPK, procedurally, Ombudsman investigations do not take into account prosecutors inputs.

It is the investigators, not the prosecutors, which make the recommendation to prosecute. The investigators recommendation is proposed directly to the head of the Office of the Ombudsman the Ombudsman himself who alone makes the decision to proceed or not. If the Ombudsman decides to prosecute, the case is then forwarded to the institutions Office of the Special Prosecutor.Bolongita, Emil P. An Exception To The Rule?. U4 Anti-corruption Resource Center Issue. August 2010: p. 14

The Ombudsman prosecutors pursue whatever case is handed to them by the Ombudsman. They do not play a role in the decision to prosecute. This process is a key problem pointed out by the prosecutors themselves: they are assigned cases to prosecute without, in their view, sufficient evidence. They argue that the dismissal and withdrawal of many Ombudsman cases prior to trial in the Sandiganbayan is not their fault, but the failure of investigators who did not gather the required evidence.Bolongita, Emil P. An Exception To The Rule?. U4 Anti-corruption Resource Center Issue. August 2010: p. 14TO PROSECUTE OR NOT?: OMBUDSMAN v KPKSpecifically, Ombudsman prosecutors argue that the decision of the investigators to recommend prosecution only utilizes the criteria of probable cause (i.e. investigators are only asking is there evidence to show that the accused probably committed the alleged offense?). From their perspective, the decision to prosecute needs to apply more stringent criteria (i.e. investigators should be asking does the evidence prove guilt beyond reasonable doubt?). Because the investigators provide evidence that only show probable cause, Ombudsman prosecutors contend the defendants can, more often than not, sow reasonable doubt and get their cases dismissed. This disconnect could probably be bridged if the investigators and prosecutors would communicate with each other. More importantly, this issue might be resolved if the Ombudsman let the prosecutors, not the investigators, make the determination and recommendation to prosecute. This would entail changing an internal rule that is within the authority of the Ombudsman to amend. However, to date, the policies and practices that divide the processes of investigation and prosecution at the Ombudsman remain unchanged.Bolongita, Emil P. An Exception To The Rule?. U4 Anti-corruption Resource Center Issue. August 2010: p. 14CODAL ON DUTY OF OMBUDSMANThe Ombudsman should "act promptly on complaints filed in any form or manner against officers or employees of the Government, or of any subdivision, agency or instrumentality thereof, including government-owned or controlled corporations, and enforce their administrative, civil and criminal liability in every case where the evidence warrants in order to promote efficient service by the Government to the people (Section 13, R.A. 6770).

The Ombudsman should give priority to complaints filed against high ranking government officials and/or those occupying supervisory positions, complaints involving grave offenses as well as complaints involving large sums of money and/or properties. (Section 15, R.A. 6770) ____________________________________________HOW IS CAPACITY TO PROSECUTE MEASURED?The Ombudsmans performance can be gauged by its capacity to prosecute (measured by the conviction rate) and its relations with the public.Human Development Network. The Office Of The Ombudsman: Is There An Institutional Weakness?. PHDR Issue Number 2. 2008-2009. P. 3.WHEN OKAY AND WHEN DISMAY The Office of the Ombudsman (OMB) was most popular during Marcelo's leadership, exhibiting 'moderate' sincerity in fighting corruption. Under Gutierrez' leadership, however, the Ombudsman's anti-corruption efforts are found to be 'mediocre'.Human Development Network. The Office Of The Ombudsman: Is There An Institutional Weakness?. PHDR Issue Number 2. 2008-2009. P. 3.CASES OF APPARENT ACTION OR INACTIONThe Ombudsman's dismal performance is further pronounced by its apparent defective actions orinaction on high profile cases.

This includes: a) $2million bribery case involving Gutierrez' former boss, Justice Secretary Hernando Perez, b) P2billion peso contract between the COMELEC and Megapacific, c) Multi-million dollar deal on NBN-ZTE deal, and d) fertilizer scam.Human Development Network. The Office Of The Ombudsman: Is There An Institutional Weakness?. PHDR Issue Number 2. 2008-2009. P. 3.RATINGS OF NET SINCERITYYearNet SincerityRating (Very/SomewhatSincere Somewhat/ VeryInsincere)Ombudsman

2000-5Desierto

2001+7

2002N.A.Marcelo

2003+21

2004+28

2005+22

2006+6Gutierrez

2007+9

2008+4

The Social Weather Stations ratings of net sincerity are as follows: 'very good' for over +50 net rate, 'good' for +31 to +50, 'moderate' for +11 to +30, 'mediocre' for +10 to -10, 'poor' for -11 to -30, 'bad' for -31 to -50, 'very bad' for below -50.Human Development Network. The Office Of The Ombudsman: Is There An Institutional Weakness?. PHDR Issue Number 2. 2008-2009. P. 5WHAT MARCELO DIDAside from the additional resources given to the Ombudsman, Marcelo 're-engineered' the internal procedures at the Ombudsman, drawing from lessons learned in the practices of Ombudsmen Vasquez and Desierto. Marcelo decentralized some powers to the deputy Ombudsmen, retaining a few key powers to ensure check and balance. This delegation of powers has resulted in efficient handling of cases, without necessarily compromising the integrity of the institutionthrough sufficient checks and balance in place. Human Development Network. The Office Of The Ombudsman: Is There An Institutional Weakness?. PHDR Issue Number 2. 2008-2009. P. 5IMPORTANCE OF SPECIAL PROSECUTOR AND FIELD INVESTIGATIONMarcelo also recognized the importance of the Office ofthe Special Prosecutor and the Field Investigation Office, and thus implemented programs to strengthen the two offices recruitment of additional prosecutors (from 52 to 104 in 2003 and 113 in 2007) and investigators (from 37 to 96 in 2003 and 1588 in 2007) and trainings.Human Development Network. The Office Of The Ombudsman: Is There An Institutional Weakness?. PHDR Issue Number 2. 2008-2009. P. 5WHAT HAPPENED DURING GUTIERREZ?With Gutierrez as new Ombudsman, most of these institutional practices/policies have been undone.

Gutierrez centralized almost all decisions e.g. travel orders, information dissemination, approval/disapproval on complaints filed by the Field Investigation Office before the Preliminary Investigation Administrative Adjudication and Monitoring Office (PAMO) and entrusted approval powers to Assistant Ombudsman Mark Jalandoni and Overall Deputy Ombudsman Orlando Casimiro. (Rufo, 2008b; Office Order 20 series of 2006) The Deputy Ombudsmen for Luzon, Visayas and Mindanao, have been ordered to transfer all pending cases involving governors and vice-governors to the Office of the Overall Deputy Ombudsman.

Even the Ombudsman's official spokesman, Jose de Jesus, has to seek clearance from the Ombudsman and her 'delegates' before he can do his job as spokesperson and liaise with media. As a result of this centralized decision-making, conviction rates have dropped and the staff are demoralized. Gutierrez also strained relations with the Office of the Special Prosecutor (OSP) headed by Dennis Villa-Ignacio.Human Development Network. The Office Of The Ombudsman: Is There An Institutional Weakness?. PHDR Issue Number 2. 2008-2009. P. 5ANOTHER INSITUTIONAL STRENGTH DURING MARCELOAnother institutional strength that Marcelo built on during his leadership was the Ombudsman's good relations with other partner organizations in the fight against corruption (Commission on Audit, Civil Service Commission, Presidential Anti-Graft Commission, and civil society organizations such as the Transparency and Accountability Network). The Solana Covenant a covenant between the OMB, COA, and CSC was a celebrated agreement among 'like-minded institutions' towards a more coordinated approach to fighting corruption. It outlined programs of the three agencies that should not duplicate but rather complement and strengthen each other's anticorruption efforts.

When Gutierrez assumed the post as new Ombudsman, the Inter-Agency Anti-Graft CoordinatingCouncil, composed of the OMB, COA and CSC, was deactivated - as chair of the IAAGCC, she simplydid not convene the council.Human Development Network. The Office Of The Ombudsman: Is There An Institutional Weakness?. PHDR Issue Number 2. 2008-2009. P. 6

The Ombudsman 'wasted' resources to implementing a program that was similarly implemented by the CSC - Oplan Red Plate. The result of uncoordinated efforts is but of course duplication of programs such as the Oplan Red Plate, which should have been a CSC program under the Solana agreement.Human Development Network. The Office Of The Ombudsman: Is There An Institutional Weakness?. PHDR Issue Number 2. 2008-2009. P. 6POOR LEADERSHIPThe apparent weakness of the Ombudsman as an institution is the doing of poor leadership. The low conviction rate is explained by a highly centralized system, a weakened Office of the Special Prosecutor, and a demoralized staff. This and bad relations with other anticorruption organizations contribute to the bad image of the Ombudsman and thus its growing unpopularity.Human Development Network. The Office Of The Ombudsman: Is There An Institutional Weakness?. PHDR Issue Number 2. 2008-2009. P. 6

OMBUDSMAN BUDGETThe Ombudsmans budget has tripled from P392.08 million in 2003 to P1.33 billion in 2009 during the administration of President Gloria Macapagal Arroyo, the wife of Gutierrezs law school batch mate, then First Gentleman Jose Miguel Arroyo. In five years under Gutierrez, the Offices budget grew by an annual average of 21.35 percent, or twice more than the usually allowed increase in the budgets of most other government agencies.

On top of this, the Office has also received not less than $7.2 million or P316 million in four different foreign grants and assistance, including funds committed to her predecessor, Simeon V. Marcelo, between 2005 and 2009.

Among the Offices fund infusions from abroad was a $6.5-million grant that was its share from the $21-million Philippine Threshold Program under the U.S. Governments Millennium Challenge Corporation (MCC).Mangahas, Malou and Ilagan, Karol Anne. Ombudsman Failure, Despite Floods Of Funds. Philippine Center For Investigative Journalism. February 6, 2011. OTHER FUNDSBefore this, the European Union extended a $716,600 grant managed by the World Bank to help the Office set up its Case Management System software. Until the close of the project in March 2007, the Ombudsman never got to use the software, prompting the donors to cancel a third or $194,838.96 of the grant funds.

Under AusAids Philippines-Australia Human Resources Development Facility (PAHRDF) from August 2004 to June 2009, the Ombudsman also received funds to build its internal capacity and competence for administrative and service delivery functions.

Then in December 2009, the US Agency for International Development (USAID) funded two more projects for the Office: an Integrity Project to focus on corruption cases in the regular courts, and the second, in cooperation with the American Bar Association, to provide technical assistance in identifying, formulating and lobbying for its priority legislative agenda.

That the Ombudsman has failed to produce more and better results in its campaign against corruption despite such windfalls could be traced to issues that money alone cannot resolve.Mangahas, Malou and Ilagan, Karol Anne. Ombudsman Failure, Despite Floods Of Funds. Philippine Center For Investigative Journalism. February 6, 2011. MULTIPLE CASES ON SINGLE INDIVIDUALClearly, though, Gutierrez, like her predecessors, would often file multiple cases against a single individual. This is why while the 1,210 cases listed by the Sandiganbayan enroll a total of 4,066 respondents, these actually involve only 694 persons. Some respondents are accused of multiple counts of alleged corruption.

Interestingly, of the 223 cases filed under Gutierrezs watch, almost all 221 were against one official: the mayor of Nakar, Quezon, while one each involved an Iloilo municipal mayor and a Nueva Ecija city mayor.Mangahas, Malou and Ilagan, Karol Anne. Ombudsman Failure, Despite Floods Of Funds. Philippine Center For Investigative Journalism. February 6, 2011. 1000 FILED; 223 CONVICTIONSIn any case, the Sandiganbayans database shows that the Ombudsman has filed more than 1,000 cases against senior government officials (with Salary Grade 27 and higher) from the time Gutierrez became the countrys first female Ombudsman up to December 2009. Of these cases, only 223 cases had resulted in convictions, or less than a quarter of the total.Mangahas, Malou and Ilagan, Karol Anne. Ombudsman Failure, Despite Floods Of Funds. Philippine Center For Investigative Journalism. February 6, 2011. CAUSE AND EFFECT OF MULTIPLE CASESAccording to Nepomuceno Malaluan, lawyer and Access to Information Network (ATIN) co-convenor, the filing of multiple cases depends largely on the prosecutor, and whether he sees the acts committed by the accused as distinct or continuing. Distinct acts may result in multiple cases even if these characterize the same offense. A continuing act may result in just one case.

Lawyer Jose Manuel I. Diokno, national chairman of the Free Legal Assistance Group (FLAG), says that if, for instance, a public official falsified 100 different documents, 100 counts of falsification may be filed against him. But Diokno points out that multiple cases do not apply to all forms of crime. It depends on the nature of the crime.Mangahas, Malou and Ilagan, Karol Anne. Ombudsman Failure, Despite Floods Of Funds. Philippine Center For Investigative Journalism. February 6, 2011. WHATS WORSE WITH MULTIPLE CASESWhats worrisome about the filing of multiple cases, says Diokno, is that these may be used to increase the rate of conviction. Malaluan, for his part, says that cases could be counted as separate cases in the computation of conviction rate. For media reporting on cases, he says, a clarification may only be made such that the actual number of persons convicted do not automatically correspond or could be lower than the total number of case convictions.

Diokno clarifies that multiple cases against one person for the same offense do not necessarily entail multiple efforts since trial of the cases is consolidated.Mangahas, Malou and Ilagan, Karol Anne. Ombudsman Failure, Despite Floods Of Funds. Philippine Center For Investigative Journalism. February 6, 2011. WHAT ABOUT THE MILITARY?WHEN IT comes to hailing to jail alleged crooks in the military and police, the Ombudsman practically accords star-rank officers a mere slap on the wrist.

Only 19 generals of the Armed Forces have actually been prosecuted for alleged corruption in the 22-year history of the Office of the Ombudsman.

Of the 19, one and only one, Maj. Gen. Carlos F. Garcia, was convicted, after pleading guilty to a lesser offense of bribery, and after securing a plea-bargain agreement to evade prosecution for plunder.Mangahas, Malou and Ilagan, Karol Anne. Ombudsman Failure, Despite Floods Of Funds. Philippine Center For Investigative Journalism. February 6, 2011. 100% CONVICTION RATE BY KPKSince it started operating in late 2003, the commission has investigated, prosecuted and achieved a 100-percent conviction rate in 86 cases of bribery and graft related to government procurements and budgets.Norimitsu Onishi, Corruption Fighters Rouse Resistance in Indonesia, New York Times, July 25, 2009.KPK VISIONThe KPK vision is to free Indonesia from corruption. Its duties include investigating and prosecuting corruption cases and monitoring the governance of the state. It has the authority to request meetings and reports in the course of its investigations. It can also authorize wiretaps, impose travel bans, request financial information about suspects, freeze financial transactions and request the assistance of other law enforcement agencies. It also has the authority to detain suspects, including well-known figures, and frequently does so."Vision and Mission". KPK website. http://www.kpk.go.id/id/modules/edito/content.php?id=15

HOLIEST AMONG HOLY?AS FORMER Ombudsman Simeon Marcelo tells it, he had implemented the tight security system at the Office because he had found out that some lawyers who used to work there were involved in fixing cases. They would even meet up at the Offices Quezon City headquarters to do their dirty deeds, he recounts.Ilagan, Karol Anne. Sanctum Sanctorum?. Philippine Center For Investigative Journalism. February 8, 2011.PERIOD FOR INVESTIGATIONS AND COMPLAINTSHe [De Jesus] also says there is no fixed period in the investigation of cases or complaints because of the various factors involved, such as the complexity of the allegations, the volume of evidence required, and the number of public officials/employees accused. He says that simple cases may take around five to six months to accomplish, while complex cases may take longer since the Office observes the policy of filing cases where the evidence is strong enough to secure conviction.

Ombudsman investigations are always aimed at presenting a strong case so our inquiries are always in-depth, says de Jesus. Although the standard of proof in fact-finding is only probable cause, the FIO (Field Investigation Office) investigators always aim at proof beyond reasonable doubt, or, in an administrative case, preponderance or substantial evidence. The reason behind this is to increase the chances of conviction of an offender.Ilagan, Karol Anne. Sanctum Sanctorum?. Philippine Center For Investigative Journalism. February 8, 2011.THE ILLUSION OF GUTIERREZIn the database, Gutierrez emerges as having the biggest case convictions by number of respondents. From December 2005 to December 2009, under her watch, the Office secured the conviction of 644 respondents. Because several of the same respondents are named in several cases, however, the 644 actually corresponds to only 196 persons.

Under Gutierrez, the Ombudsman has filed at least 1,210 cases with the Sandiganbayan. In addition, it inherited a backlog of 1,916 cases that were left pending from the time of Marcelo, Desierto, and even Vasquez.

Gutierrezs number is an illusory picture of good results, however. A closer review of the 223 cases she steered to conviction shows that almost all 221 cases to be exact were filed against just one official, the mayor of Nakar, Quezon province. The two other cases involved a municipal mayor of Iloilo, and a city mayor of Nueva Ecija.Mangahas, Malou and Ilagan, Karol Anne. 4 Ombudsman, 4 Failed Crusades. Philippine Center For Investigative Journalism. February 6, 2011.CANT CATCH BIG FISHESBut when it comes to catching the big fish, the record of all four Ombudsmen is similarly dismal. In this division, all four are cellar dwellers. While they all rushed to file suit against high-ranking officials or those with Salary Grade 27 (receiving an annual salary of P446,076), they all failed to snare convictions.Mangahas, Malou and Ilagan, Karol Anne. 4 Ombudsman, 4 Failed Crusades. Philippine Center For Investigative Journalism. February 6, 2011.PROS AND CONS OF MARCELOS SECURITY SETSo Marcelo had closed circuit television (CCTV) cameras installed, which he says later helped in stopping these former employees from continuing with their illegal deals. Some of these lawyers were even banned from the Office unless they had a scheduled hearing, he says.

But part of the system also entails getting a specific security pass for each floor. This means, says lawyer Jose Manuel Diokno, someone with transactions to conduct in several floors has to keep going back to the front desk to secure a new pass every time his or her business at one level is finished.

Its simply not a system that would encourage people to file complaints especially when security personnel are all over the Office, the lawyer observes. He even describes the security at the Ombudsman as tighter than in Malacaang.Ilagan, Karol Anne. Sanctum Sanctorum?. Philippine Center For Investigative Journalism. February 8, 2011.NUMBER OF PERSONNEL: OMBUDSMAN v KPKIn terms of number of personnel, the KPK is only about half the size of the Ombudsman yet it is far more productive. As of 2008, the KPK had about 580 personnel, while the Ombudsman had over 1,000 staff. A big factor in the productivity of the KPK is the composition and capability of its personnel. In this matter, the KPK and Ombudsman differ sharply.Bolongita, Emil P. An Exception To The Rule?. U4 Anti-corruption Resource Center Issue. August 2010: p. 17It took us three years to get the evidence. Kaya hindi masimulan yung preliminary investigation nung kaso ni former Justice Corona kasi yung documents wala. We only had the affidavit of the complainant, Mark Jimenez, and one or two Xerox copy (photocopy) of the alleged bank account kung saan yung deposit ginawa. But raising the money and finding the document that will incriminate the former justice, we did not have the ability to do that. Ayaw ko namang umalis sa Office na hindi ko natapos yung first step, which is the investigation. Like I said, it took us three years to gather all the evidence. So we should always encourage the institution of Mutual Legal Assistance Treaty so that it would be easy to get evidence. Katulad ng case ni dating Major General Carlos Garcia, because we already had assistance from the United States, it took us [only a few months to file the case]. We started in September, we were able to file the first case on November, and then we were able to file the plunder case during March of the following year. Ganun kabilis. So it all depends on whether the documents are complete. Marcelo, Simeon. Talk at the UP College Of Law. March 3, 2009. https://www.youtube.com/watch?v=qMWR8w9HJsQ.